If you export goods from India, you may face situations where shipments do not generate foreign exchange, such as sending samples, replacing defective products, or exhibiting goods at trade fairs. These cases raise a key compliance question: how to meet customs and RBI requirements when no payment is involved.

The GR waiver for export, formally called the Export Declaration Form (EDF) waiver, solves this issue by allowing exports without foreign exchange realisation. What was earlier known as the GR waiver has transitioned from the Guaranteed Remittance form to the current EDF system.

This guide explains the applicable regulations, including the November 2025 amendment extending the export realisation period to 15 months. It outlines when waivers apply, how to obtain them from your Authorised Dealer bank, and the limits on free-of-cost exports, helping prevent EDPMS issues and regulatory notices.

Key Takeaways

  • What it is: EDF waiver (formerly called the GR waiver) lets you export non-commercial goods (samples, gifts, replacements, exhibition items) without realising foreign exchange.
  • Do you need one?: Yes, whenever no forex is expected, you must get the waiver from your Authorised Dealer (AD) Bank before handing the shipment to customs; otherwise, an outstanding EDPMS entry and regulatory notices can follow.
  • Key limit: Most exporters can export free-of-cost items up to ₹10 lakh or 2% of their average annual export realisation (preceding 3 years), whichever is lower (annual cumulative).
  • Why it matters: The waiver enables straightforward customs clearance for bona fide non-commercial exports, but misuse prevents EDPMS closure and disqualifies shipments from export incentives.
  • Compliance timeline: As of November 2025, the export proceeds realisation period stands at 15 months, affecting how AD banks treat unpaid consignments.

What is a GR Waiver (EDF Waiver)?

The terminology around what is a GR waiver often confuses exporters navigating old and new systems. Let’s clarify the evolution and current status:

  • GR stands for Guaranteed Remittance: A legacy paper form used to declare export value before digital systems.
  • The ‘Waiver’: Official permission from your bank to export goods without realising foreign exchange for them
  • System evolution: GR form → SDF (Statutory Declaration Form) → EDF (Export Declaration Form)
  • Current reality: Customs ports running on Electronic Data Interchange (EDI) use the EDF, making ‘EDF Waiver’ the accurate modern term

Compliance risk is the same regardless of terminology. Exporting without a waiver or payment proof creates an outstanding EDPMS entry, triggering regulatory notices and possible penalties. Proper recording by your AD bank is essential to avoid these issues.

Did You Know?

RBI’s 2025 draft EXIM Guidelines propose allowing exporters to declare ‘nil’ value directly on the EDF for free-of-cost shipments, potentially eliminating separate waiver paperwork. 

When is a GR Waiver Applicable?

Having clarified what the waiver is, let’s examine when you actually need one. The Foreign Exchange Management Act (FEMA) requires foreign exchange realisation for all exports unless specifically exempted. The GR waiver for export applies to specific non-commercial scenarios in which no payment is made after the shipment.

Export of Trade Samples and Gifts

  • Trade samples sent to prospective buyers to generate future orders require waivers
  • Corporate gifts or promotional items with no commercial value fall under this category
  • All such goods must be marked ‘Free Trade Sample – Not for Sale’ on the invoice

Replacement of Defective Goods

  • Applies when you send a free replacement for a previously exported item that was damaged or defective
  • You must prove the original export and the defect claim from the buyer
  • This differs from ‘warranty repairs’, where the item returns to India for fixing

Goods for Re-export (Repair and Return)

  • Covers items imported into India for repairs, testing, or calibration, then sent back to the foreign owner
  • Since goods don’t belong to the Indian entity, no ‘sale’ occurs, and no forex inflow is expected
  • The waiver applies to the value of the goods themselves, not service charges

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Exhibitions and Trade Fairs

  • Applies to goods taken out of India for display at international exhibitions
  • These are often sold abroad (requiring forex inflow later) or brought back (re-imported)
  • Initial export requires a waiver since no immediate sale happens at the port

Monetary Limits for GR Waivers

RBI defines specific limits to prevent misuse of the ‘free’ export route while enabling legitimate business needs. These limits vary significantly based on your exporter status and sector.

Exporter Category Annual Limit Calculation Basis Special Conditions
Status Holders (Most Sectors) ₹10,00,000 or 2% Average annual export realisation (preceding 3 years), whichever is lower Cumulative annual cap
Gems & Jewellery Exporters ₹1,00,00,000 or 2% Average annual export realisation (preceding 3 years), whichever is lower Applies to gold/precious metals
Non-Status Holders AD Bank discretion No fixed entitlement; based on transaction nature Banks may apply USD 25,000 threshold

Limits for Status Holders

  • Status Holders are established exporters with recognised performance certificates.
  • Current limit: Export free-of-cost items up to ₹10,00,000 or 2% of average annual export realisation (preceding 3 years), whichever is lower
  • This is a yearly cumulative limit, not per shipment.

Limits for Non-Status Holders

  • Non-status holders lack a fixed ‘entitlement’ limit like Status Holders.
  • Approvals depend on the AD Bank’s discretion, based on the transaction’s ‘bona fide’ nature.
  • Banks often apply a threshold (e.g., USD 25,000) for general approval, though policies vary.

The ‘Nil’ Value Declaration Update (2025 Outlook)

  • RBI’s 2025 draft regulations propose a significant simplification of this process
  • New proposals allow exporters to declare ‘Nil’ value on the EDF for bona fide free-of-cost shipments.
  • This would eliminate the need for separate waiver requirements for qualifying transactions.
  • Check with your bank for operational status, as this transition finalises

How to Apply for a GR Waiver

The standard workflow involves documentation preparation, formal application submission, and bank verification. Remember, you must complete this process before handing shipments to customs.

Required Documents Checklist

  • Covering Request Letter: The primary application document
  • Proforma Invoice: Must state ‘Value for Customs Purpose Only’ and ‘Free of Cost’
  • Technical/Product Literature: To prove the item is a sample or defective part
  • Previous Shipping Bill/Invoice: Mandatory if sending a replacement for a past export
  • Re-import Undertaking: If goods are expected to return (e.g., for exhibitions)

GR Waiver Letter Format

Your gr waiver letter should follow this structure:

  • Date and Bank Branch Address
  • Subject Line: ‘Request for EDF/GR Waiver for Export of [Product]’
  • Body Paragraph 1: Reference the specific invoice number and date
  • Body Paragraph 2: Clearly state the purpose (e.g., ‘Free Trade Sample’ or ‘Warranty Replacement’)
  • Body Paragraph 3: Declaration that no foreign exchange will be realised and the value is bona fide
  • Closing: Authorised signatory with company seal

Pro Tip: Calculate your cumulative free-of-cost exports before applying. If you have already used ₹8 lakh of your ₹10 lakh annual limit, mention the remaining ₹2 lakh availability in your application. 

Common Challenges and Compliance Tips

Even with proper documentation, exporters often face issues during the waiver process due to regulatory misunderstandings or missed compliance steps. To avoid problems, keep these points in mind:

  • Incorrect value declaration: Do not understate the customs value simply because the commercial value is zero. Customs authorities require accurate valuation.
  • EDPMS closure: Waiver shipments still create EDPMS entries. Ensure your bank closes them after export proof is submitted.
  • Re-import delays: Goods sent abroad for repair must be re-imported within the permitted period, or customs duties may apply.
  • Record retention: Maintain waiver-related documents for RBI audits, as banks may request them years later.

The November 2025 FEMA amendments, which extend the realisation period to 15 months, give banks greater flexibility in handling aged receivables, but documentation requirements remain unchanged.

Maximise Earnings on Your Commercial Exports

While GR waivers simplify non-commercial shipments, revenue-generating exports require equal focus on payment efficiency. Export success depends on balancing compliance with cost-effective payment management.

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Conclusion

The GR/EDF waiver is essential for Indian exporters handling non-commercial shipments such as samples, replacements, and exhibition goods. Knowing the applicable limits—₹10 lakh or 2% for most exporters—helps avoid compliance issues and EDPMS complications. Recent changes, including the 15-month realisation extension and proposed “nil” value declarations, reflect efforts to simplify export procedures.

Effective compliance depends on clear coordination with your AD bank and staying updated on regulatory changes. Regularly review waiver usage against annual limits and adopt digital tools to streamline both compliance and payment processes for commercial exports.

FAQs

1. Is the GR waiver the same as the EDF waiver?

Yes, they are essentially the same. The Guaranteed Remittance (GR) form was replaced by the Export Declaration Form (EDF) with the introduction of the EDI system, so the correct technical term is now EDF Waiver.

2. What is the limit for free-of-cost exports under the GR waiver?

Most exporters can send free-of-cost exports up to ₹10 lakh or 2% of their average annual export realisation, whichever is lower, per year. Gems and jewellery exporters have a higher limit of ₹1 crore or 2%, whichever is higher.

3. Is a GR waiver required for sending export samples?

For low-value samples, typically under ₹10,000, a simple declaration is usually sufficient. For higher-value samples, you must obtain a waiver from your Authorised Dealer (AD) Bank before customs clearance.

4. Can export incentives be claimed on shipments with a GR waiver?

No, export incentives such as Duty Drawback or RoDTEP cannot be claimed on shipments cleared under a GR or EDF waiver, as no foreign exchange is realised for these exports.

5. Who issues the GR or EDF waiver?

The waiver is primarily issued by your Authorised Dealer (AD) Bank. In rare, high-value, or exceptional cases, the application may be referred to the Reserve Bank of India (RBI).